The following excerpt is from U.S. v. DiLapi, 651 F.2d 140 (2nd Cir. 1981):
4 The jury's reference to twelve counts presumably reflects its multiplication of the number of counts, 2, by the number of defendants, 6.
5 Allen v. United States, 164 U.S. 492, 501-02, 17 S.Ct. 154, 157, 41 L.Ed. 528 (1896).
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